Please comment and here are the 3 points to drive home.
1 Wolf numbers are not significantly impacted by hunting and trapping.
2 Wolf populations are stable and growing.
3 State if you live or hunt in Eastern Washington.
Commenting closes in 90 days and your response is limited to 5000 words. Pick and choose any of the facts that best represent you in your response.
https://www.regulations.gov/This letter has more than 8000 characters
March 15, 2019
Mr. Don Morgan, Chief
Branch of Delisting and Foreign Species, Ecological Services
US Fish and Wildlife Service, Headquarters Office, MS: ES
5275 Leesburg Pike
Falls Church, VA 22041-3803
RE: Docket # FWS–HQ–ES–2018–0097
Proposed rule: Removing the Gray Wolf (Canis lupus) From the List of Endangered and Threatened Wildlife
Dear Mr. Morgan:
Washingtonians for Wildlife Conservation is an alliance of individuals and organizations concerned with the health and well-being of Washington's wildlife, and wildlife management methods. We were formed to organize and unite wildlife interest groups to encourage management by wildlife professionals based on scientific data rather than false rhetoric and emotion. We are in complete support of the proposed rule of removing the gray wolf, canis lupus, from the list of endangered and threatened wildlife, docket number FWS–HQ–ES–2018–0097.
The science supports the proposed rule. Gray wolf numbers are stable and growing. From the Federal Register, Volume 84, Number 51, March 15, 2019, proposed Rules, pages 9655 & 9656:
The vast majority of wolves within the gray wolf entity now exist as a large,
stable or growing metapopulation (partially isolated set of subpopulations)
of more than 4,400 individuals that is broadly distributed across the northern
portions of three States in the Great Lakes area. This metapopulation is also
connected, via documented dispersals, to the large and expansive population of
about 12,000–14,000 wolves in eastern Canada. As a result, gray wolves in the
Great Lakes area do not function as an isolated metapopulation of 4,400
individuals across three States, but rather as part of a much larger
metapopulation that spans across three States of the United States and two
Provinces of Canada.
In addition to the metapopulation in the Great Lakes area, as of 2017, three
breeding pairs and four packs with no documented reproduction occur within
the gray wolf entity in Oregon, Washington, and California. These
wolves originated from large populations of approximately 15,000
wolves in western Canada and about 1,700 wolves in the northern Rocky
Mountains. Effective dispersal has been documented among California,
Oregon, and Washington as well as between these States and other
northern Rocky Mountains States and Canada. Thus, wolves in the Pacific
coast States are an extension of the metapopulation of wolves in western
Canada and the northern Rocky Mountains.
Finally, a number of lone long-distance dispersing wolves have been
documented outside core populations of the Great Lakes area and western
United States since the early 2000s. Confirmed records of individual wolves
have been reported from North Dakota, South Dakota, Utah, Colorado,
Nevada, Missouri, Indiana, Illinois, Nebraska, and Kansas. The total number
Of confirmed records in each of these States, since the early 2000s, ranges
from one in Nevada to at least 27 in North Dakota, with the latter also having
an additional 45 probable but unverified reports.
The numbers of wolves as listed in the Federal Register for Washington are low. According to the Washington Gray Wolf Conservation and Management 2017 Annual Report, which was a cooperative effort by the Washington Department of Fish and Wildlife, Confederated Colville Tribes, Spokane Tribe of Indians, USDA-APHIS Wildlife Services, and U.S. Fish and Wildlife Service, there is minimum count of at least 122 known wolves in 22 known packs, including at least 14 breeding pairs at the end of 2017. Wolves are breeding in Washington and their populations are growing rapidly with an estimated growth rate of 24% a year.
As we said earlier our mission is to encourage management by wildlife professionals based on scientific data, rather than false rhetoric and emotion. The animal-rights community is the king of rhetoric and emotion. This from CNN, “The Center for Biological Diversity called the proposal ‘a death sentence for gray wolves across the country,’ saying the animal will be hunted.” In the Northern Rocky Mountain Recovery Area, wolves have had federal protection removed by Congress in the eastern one-third of Washington and Oregon, and in the entire states of Montana, Idaho, and Wyoming. Both Wyoming and Montana have wolf hunts, and Idaho has both wolf hunting and trapping. Wolf populations are not declining in any one of these states. Where wolves have federal protections removed in the eastern one-third of Washington, they are protected under the state’s Endangered Species Act. The Confederated Colville Tribes, under their rights by the Stevens Treaty and confirmed by several court decisions, are killing wolves year-round with no bag limits on their reservation and their ceded hunting areas on the North Half. In this area wolf density per square mile is greater than anywhere in Idaho. Wolf populations continue to grow. This debunks the Center for Biological Diversity argument. State agencies are perfectly capable of managing wolves. It is time to turn control of wolf management to the states. State management is already working!
The most important factor in wolf recovery is social tolerance. Without social tolerance there will be no wolf recovery. When wolves were first introduced and wolves were protected everywhere, APHIS killed wolves to keep social tolerance. According to the US Department of Agriculture Journal of Mammalogy, APHIS killed 2,400 wolves in response to over 6,000 sheep
and cattle depredations in the Northern Rocky Mountain Recovery Area. Elizabeth Bradley’s excellent work, Effects of Wolf Removal on Livestock Depredation Recurrence and Wolf Recovery in Montana, Idaho, and Wyoming, published in the Journal of Wildlife Management, found that the best way to stop recurring depredations is to remove the entire wolf pack as soon as possible after the first depredation has occurred, because depredating becomes a learned habit. Cattlemen lose much more than just direct loss from wolves when their cows and calves are killed. Their cattle have their head on a swivel, because they are nervous due to the presence of wolves. They don’t eat as much, so they weigh less. Ranchers get less for their cattle because they come in underweight. The cattle are nervous, so the pregnancy rates are lower, and the ranchers have fewer calves. On top of that, the cows that do get pregnant, some self-abort due to stress from wolves. All these losses are huge to the ranching community, way more than the losses from cattle killed by wolves. The sheep producers suffer heavy losses as sheep are easy prey for wolves. People who live in rural areas with wolves have “skin in the game,” their livelihoods are at stake, many who have lived there for generations. These people are not going to sit by idly while wolves kill their livestock, their pets, and working animals. If nothing is being done to help them, these people will fight back, and wolves will die. Implementing this proposed rule is the best thing for wolves and people. We have stressed this before; local agencies know the needs of their communities and people better than federal bureaucrats. This proposed rule is the best thing for social tolerance and wolves by bringing control back to the states.
Finally, implementing this rule will help protect ungulate populations. Wolf populations need to be managed. Single specie management has never worked, and it will never work. Wildlife needs to be managed as an entire ecosystem. Implementing this proposed rule will allow the states to manage wolves in conjunction with prey species so both populations can be healthy. This solves all problems. Depredations will stop. Wolves depredate when the prey base is gone, because they need another protein source. Wolves aren’t going to turn vegetarian, so they turn to livestock, pets, or whatever protein source they can find. A healthy prey base also means opportunity for the hunting community. This helps social tolerance, because many rural towns depend on hunters’ dollars to survive.
In conclusion, Washingtonians for Wildlife Conservation strongly supports the proposed rule. Thank you for allowing us the opportunity to comment.
Sincerely,
Mark Pidgeon